No, we do not believe you are permitted to close a branch on a normal business day and all-day on Saturday every week under the Promissory Note and Bank Holiday Act. Our understanding is that the Act requires banks to remain open at least four and a half days each week.

According to the Illinois Department of Financial and Professional Regulation (IDFPR), a bank may close on Sundays and at noon on Saturdays without notice. In addition, a bank may select one additional day each week to remain closed by following four steps set out in the Act: (1) adopting a resolution authorizing the closure; (2) recording an officer-certified copy of the resolution; (3) publishing the resolution in a county-wide newspaper once each week for three successive weeks before the closure; and (4) submitting evidence of the newspaper publication to the IDFPR.

Although the Act does not specifically mention branches, we have previously discussed this law with a representative of the IDFPR, and they said the agency’s position is that the Act’s requirements apply to branch closings.

Consequently, we do not believe that permission to close for “one additional day” means that a bank or bank branch may close all-day Saturday and on another regular business day every week.

For resources related to our guidance, please see:

• Promissory Note and Bank Holiday Act, 205 ILCS 630/17(a) (“The following days shall be legal holidays in the State of Illinois upon which day a bank may, but is not required to, remain closed: . . . From 12 o’clock noon to 12 o’clock midnight of each Saturday shall be considered a half holiday. In addition to such holidays and half-holidays, a bank may select one day of the week to remain closed, as provided in subsection (b) of this Section.”)

• IDFPR 2022 Bank Holiday Schedule (“In addition to the holidays cited above, banks are authorized to close at 12:00 noon on each Saturday and all day on Sunday. A bank may also select one additional day of the week to remain closed by following the procedures outlined in Section 17(b) of the Promissory Note and Bank Holiday Act [205 ILCS 630/17(b)].”)

• Promissory Note and Bank Holiday Act, 205 ILCS 630/17(b) (“Any bank doing business within this State may select any one day of the week to remain closed on a regular basis upon adoption of a resolution by the board of directors of such bank designating the day selected and upon filing and publishing a copy of such resolution as hereinafter required. Any such resolution shall be deemed effective for the purpose of this Section only when a copy thereof, certified by an officer having charge of the records of such bank, is filed with the Recorder of the county in which such bank is located and published once each week for 3 successive weeks in a newspaper of general circulation in such county. Such publication shall be accomplished by, and at the expense of, the bank, and the bank shall submit to the Commissioner of Banks and Real Estate such evidence of the publication as the Commissioner shall deem appropriate. Any such selection shall remain in full force and effect until a copy of the later resolution of the board of directors of such bank, certified in like manner, terminating or altering any such prior selection shall be filed and published in the same manner as such prior resolution.”)